Dismissing the appeal of the revenue , the Tribunal held that ;since services of assessee were utilised outside India and, moreover, both accrual and receipt of income happened outside India, same was outside ambit of tax as per provisions of section 5(2) of the Act.( AY.2013-14)
DCIT v. Sudipta Maity. (2018) 172 ITD 94 (Kol) (Trib.)
S. 6(1) : Resident in India -Scope of total income -Non -Resident – Stationed in Switzerland for 331 days- Rendered his services outside India- Foreign assignment allowance received by him abroad, was not liable to tax in India [ S. 5 (2) ]